Your personal data

CA Indosuez Wealth (Miami)

POLICY FOR PROTECTING YOUR PERSONAL DATA

 

This policy is aimed at describing the conditions under which CA Indosuez Wealth (Miami) (hereafter known as the "Bank") may collect and process, in the course of its activities, the personal data of any data subject, particularly its clients and users of this Site.

Learn more about important personal data protection concepts: Appendix I

 

PERSONAL DATA

In the course of its activities, the Bank may process, whether automatically or not, personal data of natural persons: existing and potential clients, users of this Site (when they fill out online forms provided to them on this Site) and any other natural person (such as an agent or executive), these people all being individually known below as the "Data Subject".

Personal data regarding Data Subjects which the Bank collects or processes, acting as processing manager, is necessary for it to meet its legal or regulatory obligations, to enable the execution of pre-contractual measures or contracts to which the Data Subject is a party and/or to pursue the Bank's legitimate interests, while respecting the rights of the Data Subject. When such data is collected for other purposes, the Bank must first obtain the consent of the Data Subject.

With regard to Data Subjects who are clients, the Bank uses their personal data to offer them personalised offers and advice, higher-quality service, and everything they need to help make the best decisions.

In the absence of certain information regarding a client that is needed to perform a service, the Bank will not be able to provide him or her the benefit of the service for which that data had been required.

 

Purposes of personal data processing

The personal data of Data Subjects may be processed, primarily for the purposes mentioned above.

The Data Subject can access detailed information on how his or her personal data is used, both with respect to the purposes of the processing and the legal bases that enable the Bank to process his or her data, and how that data may be transferred to non-member states of the European Union.

Learn more about each process and related data usage (Appendix II)

 

Storing personal data

This personal data is processed and stored for as long as needed for the intended purpose, and no longer than for a period corresponding to the duration of the contractual or business relationship, plus whatever time is needed for the liquidation and consolidation of rights and for the statutes of limitations and avenues of appeal to lapse.

To meet its legal obligations or respond to requests from regulators and administrative authorities, as well as for the purposes of historical, statistical, or scientific research, the Bank may archive the data under the conditions set out by applicable regulations.

 

Rights of the Data Subject

The Data Subject, at all times, has the following rights, under the conditions set out by applicable regulations:

  • the right to access his or her personal data;
  • the right to have his or her data rectified if inaccurate or incomplete;
  • the right to object, on legitimate grounds, to the processing of his or her data;
  • the right to request the erasure of his or her data when it is no longer needed for the purposes for which it was collected or processed, or when the Data Subject withdraws consent (when the processing of the data in question requires such consent);
  • the right to request restrictions on the processing of his or her data; and
  • the right to request the portability of the data entrusted to our establishment on the basis of the consent of the Data Subject or for the purposes of performing a contract: for the Data Subject, this right consists of receiving his or her data in digital format.

The Data Subject may also, at any time and without justification, oppose the use of his or her data for the purposes of commercial prospecting, including profiling1 when it is linked to that purpose, by the Bank or by third parties, or when the processing is legally based on consent, withdraw his or her consent, by writing a letter to CA Indosuez Wealth (Miami), 600 Brickell Avenue, 37th floor, Miami, Florida, 33131, Attn: Chief Compliance Officer  Postage fees shall be reimbursed upon request by the Data Subject.

The Data Subject may exercise his or her rights by contacting the Bank’s Chief Compliance Officer, whose contact information appears below in the section entitled "Data Protection Officers".

In support of his or her request, the Data Subject may use the rights exercise form below (Appendix III).

The Data Subject is informed that exercising some of the aforementioned rights may prevent the Bank from providing him or her with certain products or services in some cases.  

 

Data Protection Officer (DPO)

The Bank has designated a Data Protection Officer, whom the Data Subject may contact at the following address: david.ruiz@ca-cib.com; 600 Brickell Avenue, 37th floor, Miami, Florida 33131, Attn: Chief Compliance Officer.

 

Complaints to Authorities

The data Subject may, in the event of a dispute, file a complaint with the CNIL, whose contact information appears on the website accessible from the following link (http://www.cnil.fr).

 

Information

By contacting the DPO, the Data Subject may access detailed information on his or her rights and how his or her personal data is being used, in particular with respect to the purposes of processing, the legal bases that enable the Bank to process data, its storage periods, its recipients, and, if applicable, its transfer to countries outside the European Union as well as the guarantees implemented.

 

Professional Secrecy

The transactions and personal data of Data Subjects are covered by professional secrecy, to which the Bank is bound in accordance with its legal and regulatory obligations.

However, in order to meet those obligations, the Bank may be required to disclose information regarding those Data Subjects who are clients to legally authorised judicial or administrative authorities.  Thus, for example, some information may be sent to the tax authorities (declaring the opening of accounts, declaring investment income).

Furthermore, each Data Subject who is a client expressly authorises the Bank to share data about him or her and update that data with the following third parties:

  • the central body of the Crédit Agricole Group, as defined by the French Monetary and Financial Code, so that said body can meet its legal and regulatory obligations for the benefit of the entire Group;
  • any entity of the Crédit Agricole Group, for commercial prospecting or contracting purposes;
  • any mediators, officers of the court, or ministerial officials in the course of their debt collection duties, as well as people involved in the transfer or reassignment of debts or contracts;
  • the recipients of funds transfers and their payment service providers, for the purposes of fighting money laundering and terrorism financing, and in accordance with international sanctions and embargo regulations;
  • the Bank's partners, in order to enable clients to benefit from the advantages of the partnership it joined, if any, and solely in the context of partnership agreements;
  • companies of the Crédit Agricole Group responsible for the management and prevention of operational risk (risk assessment, security and prevention of delinquencies and fraud, combating money laundering, etc.) on behalf of all entities of the Group;
  • any entity of the Crédit Agricole Group in the event of pooled resources or business consortiums in order to enable such entities to carry out the purpose of their joining together;
  • subcontractors of the Bank, and in particular those which participate in account management and in offering financial, banking, and/or insurance products, and solely for the purpose of the subcontracting work;
  • Crédit Agricole SA or any entity of the Group, and their subcontractors, in the context of setting up computer systems for analysing the data of clients of the Crédit Agricole Group's entities with the aim of creating predictive algorithmic models for the purposes of (i) entering into, managing, and performing contracts regarding financial, banking, and/or insurance products, (ii) improving the services provided to clients and the suitability of the financial, banking, and/or insurance products offered to clients, (iii) creating statistics and actuarial studies and simulations regarding the contracts entered into with the Bank and (iv) combating fraud;
  • the client also authorises the Bank to communicate his or her personal contact information (within the limits of what is required for the survey) to survey or polling institutes, acting solely on behalf of the Bank, for statistical purposes, with the understanding that he or she is not required to answer their requests, and that his or her data is destroyed after processing. 

Finally, the Data Subject expressly authorises the Bank to send him or her, by e-mail or by such other method agreed by the Data Subject and the Bank, any information about him or her, which may be covered by professional secrecy.

The list of personal data recipients may be sent to the Data Subject upon simple request by him or her to the Bank, at 600 Brickell Avenue, 37th floor, Miami, Florida, 33131, Attn: Chief Compliance Officer.

 

1"profiling": any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements (art. 4 parag. 4 of Regulation 2016/679 of 27 April 2016).

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